© 2018 by NCX SG PTE. LTD | UEN: 201734895N

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1.     NCX SG Pte Ltd (UEN 201734895N) Privacy Policy - Last updated on 3 April 2018

(a)     NCX SG Pte Ltd (NCX) is committed to ensuring the privacy of all information it collects.  Information supplied to NCX will              only be used for the purposes for which it was collected or as consented to by you.


(b)     NCX is a company registered in Singapore and is required to comply with the Personal Data Protection Act of Singapore              (PDPA). In keeping with this legislation and its general approach to business, this Privacy Policy sets out NCX's practice in              the collection, use and disclosure of personal information.

2.     Information collected

(a)     NCX collects personal information concerning its customers, users or visitors of its websites, social media channels, products          or services. This information is only collected where necessary. 

(b)     The type of personal information collected and held by NCX will depend upon the reason for its collection.  This inevitably            involves a diverse range of information but may include full name, residence and contact details, date of birth, gender,                   copies of identity documentation (such as passport, driver’s licence and utilities bills), billing information (such as payment              card details and bank account details) and information about the services you have used.

(c)     Where reasonably possible, NCX will only collect information from the individual to whom it relates.  However, in completing          certain regulatory requirements, NCX may collect personal information about an individual from other sources.  Frequently            this will be collected from NCX forms but it may also be collected from email, social media, letters or other forms of                    communication, through the use of its services and third party identity verification service providers.

3.     Sensitive information

Some of the personal information collected by NCX may be classed as sensitive information. This would include information on disabilities, racial or ethnic origin, religious beliefs or criminal background. Sensitive information would only be collected to satisfy legislative requirements or to meet special needs.

4.     Use and disclosure of information collected

(a)     Personal information, including sensitive information, is only collected where it is necessary for the purposes of our business          including customer verification and due diligence (which may also be obtained from third parties including information                   vendors and third party identity verification services in order to prevent money laundering, terrorism financing and fraud),              customer support and maintenance, to provide and develop services that you require including via third parties, to                        communicate with customers, users or visitors of NCX’s websites, administrative need or to meet legislative requirements.

(b)     Personal information collected for a particular purpose will not be used for any other purpose, unless we obtain your                      consent, or if it is for a secondary purpose is both related to the primary purpose of collection and the individual would                  reasonably expect the organisation to use or disclose the information for that secondary purpose.

(c)     Personal information will only be disclosed to third parties for purposes other than the primary or secondary purpose with              the written consent of the person concerned, unless otherwise prescribed by law.

(d)     NCX is authorised to use or disclose personal information if it reasonably believes that such disclosure is necessary to lessen           or prevent a serious and imminent threat to the life or health of the individual or any other person.

(e)     NCX is also authorised to disclose personal information to appropriate law enforcement agencies to assist in the prevention,          detection, investigation, prosecution or punishment of criminal activities or otherwise necessary for one or more                             enforcement related activities conducted by, or on behalf of, an enforcement agency.

4.2     Direct marketing

(a)     You give your express and informed consent to us using your personal information to provide you with information and to              tell you about our products, services or events or any other direct marketing activity (including third party products, services,          and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and                        telephone (Direct Marketing Communications).


(b)     Without limitation to the above paragraph, if you have provided inferred or implied consent (e.g. not opting out where an               opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct                         Marketing Communications given the transaction or communication you have had with us, then we may also use your                    personal information for the purpose of sending you Direct Marketing Communications which we consider may be of                    interest to you. 


(c)     If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this section,            you may ask us not to send you any further information about products and services and not to disclose your information to            other organisations for that purpose.  You may do this at any time by using the “unsubscribe” facility included in the Direct            Marketing Communication or by contacting us via the details set out at the bottom of this document.

5.     Consent to use

By providing any personal information to NCX or by using the NCX’s website(s) or any social media channels, all users fully understand and freely consent to the collection, use and disclosure of such information.

6.     Access to information collected

(a)     Upon written request NCX will provide individuals to access and correct personal information held about them.  This                        enables it to ensure that information is accurate, relevant, up-to-date, complete and not misleading.


(b)     If NCX denies a request for access, a reason will be provided. Access may be denied if such access would be unlawful,                   frivolous or vexatious; infringe on the privacy of other individuals; pose a serious and imminent threat to the life or health of            any individual; interfere with existing or anticipated legal proceedings; or other valid reasons for exclusion in line with                      relevant legislation.

7.     Security of information collected

(a)     NCX is committed to maintaining a secure environment for all personal information collected, used or disclosed.  NCX will              take all reasonable precautions to protect data from loss, misuse, unauthorised access or disclosure, alteration or                             destruction.


(b)     Personal information is retained no longer than is necessary.  Once operational needs have been satisfied, personal                        information will only be retained for the minimum period specified by legislation and then disposed of in a lawful and secure          manner.


(c)     Paper-based records containing personal information are filed in secure environments. For example, NCX may store                        personal information in secure containers such as filing cabinets, safes or compactuses as a safeguard against unauthorised            access.


(d)     Personal information collected via NCX's website will be done by sufficiently secure means. 


(e)     Access to either paper-based or computerised records will only be granted to NCX’s staff where there is a demonstrated                 need for this access in accordance with that staff member's duties or responsibilities.  No other staff or external                                organisations will be entitled to access this information.


(f)     However, NCX will provide access to information to a law enforcement agency or other government agency if such access is           legally warranted in the course of an official investigation.

8.     Cookies and Identifiers 

(a)     NCX may use “cookies” to enhance users’ experience. User’s web browser places cookies on their hard drive for record-                keeping purposes and sometimes to track information about them. A user may choose to set their web browser to refuse               cookies, or to alert them when cookies are being used. If they do so, note that some parts of the Site may not function                   properly.


(b)     To the extent practicable and reasonable, NCX will endeavour to provide you with the option of dealing with it on an                       anonymous basis or through the use of a pseudonym.  However, in the majority of circumstances it will not be practicable               for NCX to correspond with you in this manner and your personal information will be required in order to provide you with             access to NCX’s services or to resolve any issue you may have.

9.     Cross border disclosures

(a)     Any personal information NCX collects and holds may be disclosed to, and held at, a destination outside Singapore,                         including but not limited to countries where NCX has related corporations or operations and where NCX utilises third party           service providers to assist it in providing services to you.  Personal information may also be processed by staff or by other               third parties operating outside Singapore who work for NCX or for one of NCX’s suppliers, agents, partners or related                    companies.

(b)     As NCX uses service providers and platforms which can be accessed from various countries via an Internet connection, it is              not always practicable to know where your information may be held.  If your information is stored in this way, disclosures                 may occur in countries other than those listed above.

(c)     In addition NCX may utilise overseas IT services (including software, platforms and infrastructure), such as data storage                   facilities or other IT infrastructure. In such cases, NCX may own or control such overseas infrastructure or it may have entered          into contractual arrangements with third party service providers to assist NCX in providing its services to you. 

(d)     In relation to any cross-border data transfers or storage, NCX will take all reasonable steps to ensure that recipients of                   personal information are obliged to protect the privacy of your personal information and observe security standards.

(e)     By submitting your personal information to NCX, you expressly agree and consent to the disclosure, transfer, storing or                   processing of your personal information outside of Singapore.  In providing this consent, you understand and acknowledge            that countries outside Singapore do not always have the same privacy protection obligations as Singapore in relation to                 personal information.  However, NCX will take steps to ensure that your information is used by third parties securely.

10.     Third party websites

NCX’s website may contain links to or from external websites which are not subject to this Privacy Policy. This Privacy Policy applies only to the information NCX collects on its website. NCX does not control the content or links that appear on other websites and is not responsible for the practices employed by websites linked to or from NCX’s website. In addition, third party websites or services, including their content and links, may be constantly changing. Third party websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to NCX’s website, is subject to that website’s own terms and policies.

11.     Notification of changes

NCX may revise this Privacy Policy from time to time, without notice to users. If NCX decides to change this Privacy Policy, it will post the revised statement here. Please note that NCX’s use of personal information will be based on the most current version of this Privacy Policy, as amended.

12.     Access to and correction of your personal information

You are entitled to have access to any personal information relating to you which we hold, except in some exceptional circumstances provided by law (including the PDPA).  You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out below.

13.     Interaction of this Privacy Policy with contracts

(a)     This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons.              However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such                           instances, NCX may incorporate the terms of this policy such that:

(1)     certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give          rise to contractual obligations onto NCX, but do create contractual obligations on the other party to the contract; and

(2)     the consents provided in this policy become contractual terms provided by the other party to the contract.

(b)     By using our website or by purchasing a product or service from NCX, where you have been provided with a copy of our                 Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:


(1)     to provide the consents given by you in this Privacy Policy; and


(2)     that you have been informed of all of the matters in this Privacy Policy.

14.     Contact and complaints

For further information about this Privacy Policy, the practices of NCX or complaints, please contact:

enquiries@ncx.com.sg, or write to NCX at 16 Raffles Quay, #33-02 Hong Leong Building Singapore 048581